SONOCO PRODUCTS COMPANY
CONFLICT MINERALS POLICY
Congress adopted Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act with the intention of furthering the humanitarian goal of ending the extremely violent conflict in the Democratic Republic of the Congo (DRC), which has been partially financed by the exploitation and trade of “Conflict Minerals” originating in the DRC. “Conflict Minerals” are defined by the Securities and Exchange Commission (SEC) as cassiterite, columbite-tantalite, wolframite, gold, and their derivatives, which are limited to tin, tantalum, and tungsten that have contributed to the financing of armed groups responsible for human rights violations.
Congress chose to use the securities laws disclosure requirements to enhance transparency and bring greater public awareness of the source of issuers’ Conflict Minerals and to promote the exercise of due diligence on supply chains. As required by Dodd-Frank, the SEC has adopted a rule that requires publicly traded companies annually to conduct a good faith reasonable inquiry to determine whether any Conflict Minerals that are necessary to the functionality or production of products they manufacture, or for which they contract the manufacture (Necessary Conflict Minerals), originated in the DRC or an adjoining country, or are from recycled or scrap sources. The results of the inquiry are required to be disclosed annually in a report on Form SD – Specialized Disclosure Report filed with the SEC.
Some of Sonoco’s products may contain tantalum, tin, tungsten or gold. Because Sonoco does not purchase these minerals directly from mines or smelters, we must rely on source information provided by our suppliers. We have developed a program to carry out supply chain due diligence with reference to the Organisation for Economic Co-operation and Development (OECD) guidance approved by the SEC. Our efforts are not intended altogether to ban the use of tantalum, tin, tungsten and gold that originate in conflict-affected and high-risk areas when they are sourced in accordance with existing international standards. We recognize that avoiding the sourcing of any of these minerals from these areas would cause a de facto embargo with serious adverse impact on the living conditions of local populations. However, we are committed to responsible sourcing of conflict free minerals, and we support efforts to eliminate the use of tantalum, tin, tungsten, and gold that are not conflict-free.
Sonoco requires suppliers that provide us with tantalum, tin, tungsten or gold, or products containing these components, which are then incorporated into products we manufacture for sale, to submit information to us that allows us to trace the minerals back through the supply chain. We expect our suppliers to adopt policies and establish their own due diligence programs to ensure conflict free supply chains, and to provide us only with minerals or products that are conflict free. If we become aware of a supplier whose supply chain includes minerals that are not conflict free, we will take appropriate steps to remedy the situation in a timely manner, including reassessment of the supplier relationship. We expect our suppliers to take similar measures with their suppliers.
Conflict Minerals Disclosure